• Deborah

In anticipation of secondary legislation due in Spring 2022, the UK’s HM Treasury launched a consultation paper to gather views on potential amendments to the Money Laundering, Terrorist Financing and Transfer of Funds Regulations (MLRs). The consultation document, published on July 22nd, invites views from industry, law enforcement, supervisors and the broader public and civil society on five broad topics:


1. Risks, impacts and compliance costs on businesses and their services relating to potential amendments on exemptions to the scope of the regulated sector presenting low risk of money laundering and terrorist financing, including:

  • Account Information Service Providers (AISP)

  • Payment Initiation Service Providers (PISP)

  • Bill payment service providers (BPSP)

  • Telecoms, Digital and IT Payment Service Providers (TDITPSP)

  • Art Market Participants (AMP)

Specifically for the AMP, the HM Treasury also invited views on the scope of the definition of AMP; for example whether it should include those who trade in the sale and purchase of digital art.


2. Supervisory enhancements relating to amendments to the:

  • Current approach to accessing and viewing the Suspicious Activity Reports (SARs) by supervisors

  • Activities that make a relevant person a financial institution to align with Financial Services and Markets Act (FSMA)

3. Strengthened supervisory regime to include:

  • A definition of proliferation financing aligned with FATF definition

  • Limited partnership formation

  • Alignment of reporting obligations on discrepancies in beneficial ownership information

3. Information sharing and gathering, particularly:

  • Reciprocal protected sharing from relevant authorities, including an expanded list of recognised ‘relevant authorities’ with access to an information sharing gateway

  • Further supervisory powers to the Financial Conduct Authority (FCA)

4. Cryptoasset sector and applicability of:

  • Funds Transfer Regulation (FTR)

  • General Data Protection Regulation (GDPR)

The consultation remains open until October 14, 2021 and email responses should be sent to Anti-MoneyLaunderingBranch@hmtreasury.gov.uk .


In addition to the consultation, HM Treasury has published a separate call for evidence on UK’s AML/CTF regulatory and supervisory regimes. The call for evidence aims to gauge the overall effectiveness of the regimes, their extent (i.e. the sectors in scope), and the application of particular elements of the Regulations.

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